Morales v. Brown, et al.

Filing 19

STIPULATION and ORDER to continue Scheduling Conference from 4/7/2015 to 6/15/2015 at 09:00 AM in Courtroom 9 (SAB) before Magistrate Judge Stanley A. Boone. Signed by Magistrate Judge Stanley A. Boone on 3/16/2015. (Hernandez, M)

1 Raymond P. Boucher, State Bar No. 115364
Hermez Moreno, State Bar No. 72009
2 BOUCHER LLP
21600 Oxnard Street, Suite 600
3 Woodland Hills, California 91367-4903
Tel:
[phone]
4 Fax:
[phone]
Emails: [e-mail]
5
[e-mail]

Jason K. Feldman, State Bar No. 213386
Ian Wallach, State Bar No. 237849
FELDMAN & WALLACH
606 Venice Boulevard, Suite C
Venice, California 90291
Tel:
[phone]
Fax:
[phone]
Emails: [e-mail]
[e-mail]

6 Mark A. Ozzello, State Bar No. 116595
Suzy E. Lee, State Bar No.271120
7 ARIAS, OZZELLO, & GIGNAC, LLP
6701 Center Drive West, Suite 1400
8 Los Angeles, CA 90045
Tel:
[phone]
9 Fax:
[phone]
Emails: [e-mail]
10
[e-mail]
11 Attorneys for Plaintiff,
Miguel Angel Sanchez Morales
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION
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MIGUEL ANGEL SANCHEZ MORALES ,

Case No. 1:14-CV-01717-LJO-SAB

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Plaintiff,
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v.

JOINT STIPULATION AND REQUEST
TO CONTINUE APRIL 7, 2015
SCHEDULING CONFERENCE; ORDER

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EDMUND G. BROWN, JR., GOVERNOR;
19 JEFFREY BEARD, SECRETARY OF THE
CALIFORNIA DEPARTMENT OF
20 CORRECTIONS AND REHABILITATION
(CDCR); MATTHEW CATE, FORMER
21 SECRETARY OF THE CDCR; MARTIN
BITER, WARDEN OF THE KERN VALLEY
22 STATE PRISON (KVSP0; ANTHONY
HEDGPETH, FORMER WARDEN OF
23 KVSP; and DOES 1 through 50, inclusive,
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Defendant.

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By and through their respective counsel, the parties stipulate and agree as follows:

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WHEREAS, on February 20, 2015, the Court entered an Order Setting Scheduling

28 Conference, pursuant to which the parties must meet and confer on a discovery plan by March 18,

1 2015 (ECF No. 15);
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WHEREAS, on March 12, 2015, Judge Boone signed the proposed order providing

3 Defendants Beard, Cate, and Biter until March 19, 2015 to file a responsive pleading (ECF No.
4 17), and Defendants intend to file a motion to dismiss;
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WHEREAS, Defendants Brown and Hedgpeth have not yet been served or appeared in the

6 action;
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WHEREAS, counsel for the parties agree that a continuance is warranted to allow

8 Plaintiffs adequate time to review and evaluate Defendants’ response to the Complaint prior to
9 meeting and conferring regarding scheduling;
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WHEREAS, counsel for the parties further agree that judicial economy will be best served

11 if the Scheduling Conference is continued for sixty (60) days to allow the Court to rule on the
12 motion to dismiss Defendants intend to file and to allow adequate time for a meaningful
13 conference of the parties;
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NOW THEREFORE, the parties hereby stipulate and request that the Court continue the

15 Scheduling Conference and any deadlines pertaining thereto for sixty (60) days.
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Dated: March 16, 2015

BOUCHER, LLP

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By:

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/s/ Hermez Moreno
HERMEZ MORENO
BOUCHER, LLP
Attorneys for Plaintiff

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22 Dated: March 16, 2015
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KAMALA D. HARRIS
Attorney General of California
CHRISTOPHER J. BECKER
Supervising Deputy Attorney General
By:

/s/ Jon S. Allin
JON S. ALLIN
Deputy Attorney General
Attorneys for Defendants
Beard, Cate, and Biter

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2

ORDER
GOOD CAUSE APPEARING, the Court hereby approves this Stipulation by and

3 between the parties and continues the Scheduling Conference to June 15, 2015 at 9:00 am
4 before Magistrate Judge Stanley A. Boone.
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6 IT IS SO ORDERED.
7 Dated:
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March 16, 2015
UNITED STATES MAGISTRATE JUDGE